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Torrid California Transparency in Supply Chains Act Disclosure

Torrid Holdings Inc. and its subsidiaries including, but not limited to, Torrid LLC (collectively “Torrid”) is committed to providing our customers with top-quality products at a reasonable price that are also manufactured responsibly. Torrid expects all workers, with an emphasis on those who manufacture Torrid products, to be treated fairly and with dignity and respect, and that the products themselves are made in an environmentally sustainable manner. In addition, Torrid requires its business partners who manufacture products for us or supply products to us for resale, to fully comply, at a minimum, with all federal, state, regional, local or other jurisdictional laws, rules and regulations, including those by a government-authorized agency, as well as relevant international laws and industry standards.

In accordance with the California Transparency in Supply Chain Act, below please find information regarding the efforts Torrid is taking to eradicate slavery and human trafficking from our supply chain, while maintaining social accountability and supply chain transparency.


Verification

Torrid is committed to fair labor practices throughout our supply chain. To establish clear guidelines for responsible operation, we developed the Vendor & Business Partner Code of Conduct (“Code of Conduct”) to help ensure that every relationship we enter – whether it’s with a manufacturer or provider/supplier of products we resale, consistently operates in accordance with Torrid’s standards. Compliance with the Code of Conduct is required in each vendor agreement, and each supplier manufacturing Torrid products is required to post the Code of Conduct in all factory locations. Torrid retains the right to terminate its relationship with its vendors or suppliers if Torrid finds that such vendors or suppliers are violating anti-slavery and or human trafficking laws or the Code of Conduct, respectively.

The Code of Conduct is based on international social accountability standards and several specific areas of conduct, including the prohibition of forced and child labor. All areas of conduct are annually assessed during on-site audits conducted by a third-party auditor who identifies and verifies that suppliers are not at risk for violating any anti-slavery and or human trafficking laws. The Code of Conduct is regularly reviewed and reinforced as business needs and requirements change.


Audits

Audits may be performed to ensure compliance of the Code of Conduct. Torrid, or any organization acting on Torrid's behalf, may carry out audits, including material suppliers with or without notice, on the premises of our vendors and supply chain partners at any time. Additional auditing partnerships allow for methods of validation to increase transparency of production facilities.


Certification

By acknowledging the provisions in the Code of Conduct, all vendors and supply chain partners agree to the standards outlined therein, including the prohibition of any form of forced labor or human trafficking.


Internal Accountability

Torrid’s SVP, Product Supply Chain, oversees supplier auditing to ensure compliance with the Code of Conduct. All audits are carried out by external, independent third parties. Any supplier that fails to comply with applicable laws or ethical business practices may be subject to immediate business suspension or termination. Additional processes may be defined and implemented to ensure that vendors are complying with the Code of Conduct and that proper management systems are in place.


Training

Torrid has a program for regularly training our employees with responsibility over our products about the importance of compliance with the standards put forth in our Code of Conduct, how to identify and avoid potential violations of these standards, and w hat they should do if they suspect a manufacturer or product provider has failed to comply with the standards. We also provide the ability for our employees to report any concerns they may have about these matters in a confidential manner, free from any threat of retaliation.

Torrid is committed to all legal and ethical business practices and demands the same commitment from each of our suppliers through the Code of Conduct.